Header graphic for print
Chicago IP Litigation Tracking Northern District of Illinois IP Cases

Swarming Does Not Create Jurisdiction

Posted in Pleading Requirements

Millenium TGA v. Doe, No. 10 C 5603, Slip Op. (N.D. Ill. Sep. 26, 2011) (Manning, J.).

Judge Manning dismissed plaintiff Millenium TGA’s case against a Doe defendant identified by its computer IP address ("Doe") for lack of personal jurisdiction. Doe was not an Illinois resident. And Millenium TGA offered no proof that Doe’s actions in allegedly using Bit Torrent to download copyrighted video files were targeted at Illinois. Being part of a Bit Torrent "swarm" that downloaded a video did not rise to the level of targeting Illinois.